The Trump Administration’s handling of antitrust enforcement issues is generally viewed as a wild-card — meaning there are issues of concern or focus that may not fit the “traditional” antitrust enforcement model. Depending...more
9/3/2025
/ Antitrust Division ,
Antitrust Investigations ,
Big Tech ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Hart-Scott-Rodino Act ,
Leniency Programs ,
Merger Reviews ,
Mergers ,
Pharmaceutical Industry ,
Price-Fixing ,
Trump Administration
Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed -...more
In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects...more
Last week, the Justice Department announced that Cadence Design Systems Inc. (Cadence), a global electronic design automation (EDA) technology company based in San Jose, California, agreed to plead guilty to a conspiracy to...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
Well, we are in a new era — a fundamental change has occurred, long in the making. National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted...more
8/7/2025
/ Bureau of Industry and Security (BIS) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Due Diligence ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Training
DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more
8/5/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
International Trade ,
National Security ,
PRC ,
Risk Management ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
7/28/2025
/ Consumer Protection Laws ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Investigations ,
Tariffs ,
Trade Policy ,
Trump Administration
A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports.
In this episode, Michael Volkov explores how the Trump Administration is reshaping the...more
Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate...more
7/22/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Financial Crimes ,
Money Laundering ,
Risk Management ,
Significant Transnational Criminal Organization ,
Supply Chain
The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more
7/22/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Cuban Assets Control Regulations (CACR) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Huawei ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __...more
7/17/2025
/ China ,
Court of International Trade ,
Customs ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Investigations ,
Jurisdiction ,
Penalties ,
Tariffs ,
US ex rel Tracy Schutte et al v SuperValu Inc et al ,
Whistleblowers
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
7/16/2025
/ Anti-Dumping Duty ,
Customs ,
Department of Justice (DOJ) ,
Duties ,
Enforcement ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Penalties ,
Section 301 ,
Tariffs ,
Whistleblowers
Could your supply chain be funding cartels without you realizing it?
In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more
7/13/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Cartels ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Financial Crimes ,
Risk Management ,
Supply Chain
Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal...more
What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it?
Can a robust post-acquisition response really save a parent company from prosecution?
In this episode, Michael...more
The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more
DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more
In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more
6/24/2025
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Sanction Violations ,
U.S. Treasury ,
Ukraine ,
Venture Capital ,
White Collar Crimes
The Justice Department has returned to the FCPA enforcement arena -- in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more
The Justice Department has returned to the FCPA enforcement arena -- in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more
DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change. Here is my...more
The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more